Plaze, Inc. and Apollo Aerosol Industries LLC v. Chris K. Callas

CourtCourt of Chancery of Delaware
DecidedMarch 29, 2018
Docket2017-0432-TMR
StatusPublished

This text of Plaze, Inc. and Apollo Aerosol Industries LLC v. Chris K. Callas (Plaze, Inc. and Apollo Aerosol Industries LLC v. Chris K. Callas) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Plaze, Inc. and Apollo Aerosol Industries LLC v. Chris K. Callas, (Del. Ct. App. 2018).

Opinion

COURT OF CHANCERY OF THE STATE OF DELAWARE

TAMIKA R. MONTGOMERY-REEVES Leonard Williams Justice Center VICE CHANCELLOR 500 N. King Street, Suite 11400 Wilmington, Delaware 19801-3734

Date Submitted: December 7, 2017 Date Decided: March 29, 2018

Kevin R. Shannon, Esquire John M. Seaman, Esquire Christopher N. Kelly, Esquire E. Wade Houston, Esquire Andrew H. Sauder, Esquire Abrams & Bayliss LLP Potter Anderson & Corroon LLP 20 Montchanin Road, Suite 200 1313 North Market Street Wilmington, Delaware 19807 Hercules Plaza, 6th Floor Wilmington, Delaware 19801

RE: Plaze, Inc. & Apollo Aerosol Industries LLC v. Chris K. Callas et al. Civil Action No. 2017-0432-TMR

Dear Counsel:

This letter opinion addresses Defendants’ Motion to Dismiss under Court of

Chancery Rule 12(b)(6). For the reasons set forth below, the Motion is DENIED.

I. Background All facts are drawn from the Verified Complaint for Injunctive and Other

Relief (the “Complaint”) and the documents incorporated therein. At this stage of

the proceedings, I must take all of Plaintiffs’ well-pled facts as true and draw all

reasonable inferences in their favor. 1

1 The Complaint alleges that Defendants shredded a large quantity of documents in the month leading up to their departure and had their third-party IT vendor purge their company emails before their departure. Compl. ¶¶ 41-42. Plaintiffs explained Plaze v. Callas C.A. No. 2017-0432-TMR March 29, 2018 Page 2 of 19

Plaintiff Plaze, Inc. (“Plaze” or the “Buyer”) is a “full-service specialty

contract manufacturer of automotive, household, insecticide, and pesticide

aerosols.” 2 Plaze is the sole member of Plaintiff Apollo Aerosol Industries LLC

(“Apollo” or the “Company”). 3 In 2015, Plaze acquired Apollo from Defendants (or

the “Sellers”) for $100,000,000 pursuant to a stock purchase agreement (the

“SPA”). 4

The parties signed the SPA on November 24, 2015, and the transaction closed

on December 15, 2015. 5 The SPA sets out a mechanism for post-closing adjustments

to the purchase price, as well as a limitation on the Sellers’ post-closing

indemnification liability. The SPA contains representations and warranties by

Defendants on behalf of Apollo that are at issue in this litigation.6 These include

representations and warranties about the financial records of Apollo, Apollo’s

that the Complaint is based primarily on the company emails they were able to recover after the purge. Id. ¶ 42; Oral Arg. Tr. 51-52. 2 Compl. ¶ 9. 3 Id. ¶ 10. 4 Id. ¶ 2. 5 Id. ¶ 23. 6 Id. ¶¶ 63-66; Id. at Ex. 1, at 20-35. Plaze v. Callas C.A. No. 2017-0432-TMR March 29, 2018 Page 3 of 19

compliance with certain laws and contracts, and Apollo’s product liability exposure.

Indemnification is the sole remedy for a breach of a representation or warranty under

the SPA. 7 The SPA also contains several restrictive covenants relevant to this

litigation, including non-compete, non-solicit, and confidentiality provisions. 8 The

parties agreed that specific performance, an injunction, or other equitable relief are

necessary to enforce these provisions of the SPA. 9

After the closing, Defendants Chris Callas10 and Maria Callas continued to

work at Apollo, but the relationship soured. On March 28, 2016, Apollo and Chris

Callas entered into a mutual separation and settlement agreement (the “Separation

Agreement”) effective March 31, 2016. 11 The Separation Agreement included a

severance amount, a repurchase of LLC units, and a settlement of the purchase price

under the SPA, as well as additional representations, warranties, and restrictive

covenants applicable to Chris Callas.

7 Id. at Ex. 1, § 6.7. 8 Id. ¶¶ 25-33; Id. at Ex. 1, at 53-55. 9 Id. at Ex. 1, at 61-62. 10 At closing, Defendant Chris Callas entered into an employment agreement with Plaintiffs to continue working as CEO of Apollo. Id. ¶ 24. 11 Id. ¶ 35; Id. at Ex. 2. Maria Callas also departed Apollo on March 31, 2016. Id. ¶ 35. Plaze v. Callas C.A. No. 2017-0432-TMR March 29, 2018 Page 4 of 19

The heart of the Complaint is Plaintiffs’ contention that after the Callases

departed Apollo they started a competing business and attempted to solicit

employees from Apollo. Plaintiffs also contend that several breaches of

representations and warranties, for which Defendants owe them indemnification,

came to light during the survival period.

On June 7, 2017, Plaintiffs filed the Complaint seeking to enjoin the

competitive behavior of Defendants and compel payment of the indemnification and

tax adjustment amounts. Defendants moved to partially dismiss the Complaint on

July 7, 2017, and the Court heard oral argument on the Partial Motion to Dismiss on

December 7, 2017.

II. Analysis The Complaint contains nine counts, eight of which Defendants move to

dismiss. 12 These eight counts fall into two broad categories: (1) breaches of

restrictive covenants, for which Plaintiffs seek specific performance or injunctive

relief, and (2) breaches of representations and warranties, for which Plaintiffs seek

indemnification. Counts I through IV allege breaches of restrictive covenants.

Counts V through VIII allege breaches of representations and warranties. In support

12 Defendants have not moved to dismiss Court IX, which alleges a breach of Section 6.8 of the SPA related to the tax adjustment amount. Id. ¶¶ 132-36. Plaze v. Callas C.A. No. 2017-0432-TMR March 29, 2018 Page 5 of 19

of their motion to dismiss, Defendants first argue that the subsequent Separation

Agreement between Plaintiffs and Defendant Chris Callas settled all claims in

Counts V through VIII for breaches of representations and warranties. Second,

Defendants argue that the allegations in the Complaint fail to state a claim under

Court of Chancery Rule 12(b)(6) as to Counts I through IV and part of Count VIII.

I address each argument in turn.

A. Standard of Review When considering a motion to dismiss for failure to state a claim under Court

of Chancery Rule 12(b)(6), a court must accept all well-pled factual allegations in

the complaint as true, accept even vague allegations in the complaint as well-pled if

they provide the defendant notice of the claim, “draw all reasonable inferences in

favor of the non-moving party,” and deny the motion unless the plaintiff could not

recover “under any reasonably conceivable set of circumstances susceptible of

proof.”13

All the claims in this case hinge on the Court’s interpretation of the parties’

contracts. “Delaware adheres to the ‘objective’ theory of contracts, i.e., a contract’s

construction should be that which would be understood by an objective, reasonable

13 Savor, Inc. v. FMR Corp., 812 A.2d 894, 896-97 (Del. 2002). Plaze v. Callas C.A. No. 2017-0432-TMR March 29, 2018 Page 6 of 19

third party.” 14 “When interpreting a contract, this Court ‘will give priority to the

parties’ intentions as reflected in the four corners of the agreement,’ construing the

agreement as a whole and giving effect to all its provisions.” 15 “In giving sensible

life to a real-world contract, courts must read the specific provisions of the contract

in light of the entire contract.”16

B.

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Plaze, Inc. and Apollo Aerosol Industries LLC v. Chris K. Callas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/plaze-inc-and-apollo-aerosol-industries-llc-v-chris-k-callas-delch-2018.